Statewide MDHHS Lead Safe Home Program Environmental Investigation and Lead Hazard Control

STATEWIDE PRITOIZATION OF MICHIGAN DEPARTMENT OF HEALTH AND HUMAN SERVICES (MDHHS) ENVIRONMENTAL EBL INVESTIGATIONS PRIORITIZATION PROTCOL

Revised 1/13/17

Statewide MDHHS Lead Safe Home Program Environmental Investigation and Lead Hazard Control Enrollment Process:

1. MDHHS Childhood Lead Poisoning Prevention Program reports statewide blood lead data ≥ 5 ug/dL weekly to MDHHS Healthy Homes Section (HHS).

2. All families that have a child with a venous blood level test results ≥5 ug/dL are mailed a Lead Safe Home Program (LSHP) application and educational materials to inform families of available services.

3. MDHHS HHS attempts to contact each family by calling and/or texting (excluding City of Detroit or other local lead programs) with a BLL ≥ 10 ug/dL to ensure they received the materials and provide help with application, as needed. HHS will contact families at lower blood lead levels as staff capacity increases.

4. MDHHS LSHP staff work directly with MDHHS Childhood Lead Poisoning Prevention Program (CLPPP) staff and local health department nursing and environmental staff to enroll families in the LSHP.

5. In Flint, LSHP is working directly with local case management nonprofit to enroll all families in the LSHP. Currently in Flint, a LSHP application is not needed for the environmental investigation (EI) process and an intake form is used between local case management and LSHP, as this was declared a state and federal emergency.

Prioritization/Acceptance Consideration:

1. An approved Lead Safe Home Program (LSHP) application. This signed document provides essential demographic and financial information to meet state and federal eligibility requirements and demonstrates the family’s ability and willingness to participate. LSHP reviews each application and provides assistance to family in order to complete.

1. The magnitude of the Elevated Blood Lead (EBL)

2. The total number of children residing in the home.

3. Income of family meets federal requirements (HUD is 80% of area median income and CHIP 400 % of poverty level in Flint and 200% statewide).

4. Property taxes paid or entered into a payment plan with a balance of $1,000 or less.

5. Location – HUD and CHIP funding priority target areas or emergency declaration area. HUD target areas include the counties of Genesee, Ingham, Jackson, Kalamazoo, Kent, Lenawee, Macomb, Oakland, Saginaw and the city of Detroit. Child Health Insurance Program (CHIP) target areas are in the process of being identified, based on the general criteria written into the Medicaid State Plan Amendment (SPA).

Processing Procedure:

For a LSHP application regarding a home with a child with a blood lead level < 5 ug/dL or pregnant female:

1. If applicant is within a LSHP target area and meets eligibility requirements the applications is scored and prioritized for assistance. If the application is denied due to eligibility requirements, such as the family exceed income guidelines, MDHHS sends a resource packet. Applications for homes not located in a HUD or CHIP target area are always denied and the LSHP sends a resource packet as a primary prevention guide.

2. Once the LSHP application is received and approved, HHS provides a combination lead inspection and risk assessment (LIRA). Water sampling is performed on a case-by-case basis. HHS ranks each applicant and places on a priority list to determine when the LIRA can take place.

3. If a Regional Field Consultant RFC determines that the home has code violations that would prevent the structure from meeting LSHP state and federal requirements the RFC may continue to perform the LIRA or suspend the LIRA until such time as the home qualifies. This could include: no running water, no furnace, unsanitary conditions, not having access to the entire home, or possible illegal activities. LSHP will work with the family to meet eligibility requirements or submit an Eligibility Waiver Request to MDHHS administration for approval to proceed.

4. If lead hazards are identified, HHS meets with owner to discuss the abatement process, costs, and any necessary financial or in-kind contributions from the property owner. Abatement specifications are written, projects are bid and awarded, abatement proceeds and a final clearance is conducted.

5. The timeline for HHS response is based on the availability of Heathy Homes Section (HHS) staff*.

Applications for homes with Children with venous BLLs 5 - <10 ug/dL:

1. Once the LSHP application is received and approved, HHS scores application and prioritizes for assistance. If applicant is denied, because the family exceed income guidelines, MDHHS sends a resource packet. If the family meets income guidelines but no other eligibility criteria (e.g. delinquent taxes) , HHS works with the family to meet other eligibility requirements and/or send a MDHHS Eligibility Waiver Request form to MDHHS to proceed when families have unique circumstances.

2. Once the LSHP application is received and approved, HHS provides an EI. Water sampling is performed on a case-by-case basis. HHS ranks each applicant and places on a priority list to determine when the LIRA can take place.

3. If a RFC determines that the home has code violations that would prevent the structure from meeting LSHP state and federal requirements the RFC may continue to perform EI or suspend the EI until such time as the home qualifies. This could include: no running water, no furnace, unsanitary conditions, not having access to the entire home, or illegal activities. LSHP will work with family to meet eligibility requirements or submit an Eligibility Waiver Request to MDHHS administration to proceed.

4. If lead hazards are identified, LSHP meets with owner to discuss the abatement process, costs, and any necessary financial or in-kind contributions from property owner. Abatement specifications are written, projects are bid and awarded, abatement proceeds and a final clearance is conducted.

4. Time line for HHS response for performing EI is within two weeks*.

Applications for home with one or more children with a venous BLL (10 - <45 ug/dL):

1. For an owner-occupied home, once the LSHP application is received and approved based on the prioritization criteria above, HHS provides EI. Water sampling is performed on a case-by-case basis. If the application is denied because the family exceed income guidelines, MDHHS sends a resource packet. If the application is denied for other reasons (e.g. delinquent taxes), HHS works with the family to meet other eligibility requirements and/or send a MDHHS Eligibility Waiver Request form to MDHHS to proceed when families have unique circumstances.

2. For rental properties with an EBL ≥ 10 ug/dL (or until state formally adopts lower level), an EI is performed by HHS staff without an approved LSHP application. A LSHP application is distributed at the time of the EI, if not already received by HHS. If hazards are present, the landlord must abate the identified hazards according to regulations within 90 days upon receipt of report or the landlord may be referred to local code compliance and/or HHS Enforcement Staff for Landlord Penalty Law enforcement. LSHP will continue to partner with rental property owner to participate in LSHP in this process if the rental property owner desires.

3. If a RFC determines that the home has code violations that would prevent the structure from meeting LSHP state and federal requirements the RFC may continue to perform EI or suspend the EI until such time as the home qualifies. This could include no running water, no furnace, unsanitary conditions, not having access to the entire home, or illegal activities. LSHP will work with family to meet eligibility requirements or submit an Eligibility Waiver Request to MDHHS administration to proceed.

Timeline for HHS response for performing EI is within one week*.

Hospitalized child with EBL requiring chelation or a BLL ≥ 45 ug/dL:

1. MDHHS waives the application process and performs the EI regardless of whether home is owner occupied or a rental. Family is informed of the LSHP at this visit and HHS staff assists the family in completing and submitting application quickly. If RFC determines property meets eligibility requirements and the application is received and approved then abatement procedures begin.

2. For owner-occupied properties that are not eligible for LSHP assistance, LSHP works with family to submit MDHHS Eligibility Waiver Request to proceed. If the parent/guardian is uncooperative with respect to the abatement of the lead hazards or the property does not meet eligibility requirements, the family may be referred to Child Protective Services for additional resources and/or applicant is referred to a local program (if available) to relocate family to lead-safe housing.

3. For rental properties, the LSHP application is distributed at the time of the EI, if not already received by HHS. If hazards are present, the landlord must abate the identified hazards within 90 days upon receipt of report. Or the landlord will be referred to local code compliance and/or HHS Enforcement Staff for Michigan Landlord Penalty Law enforcement. LSHP will continue to partner with the rental property owner to participate in LSHP in this process if the rental property owner desires.

4. The timeline for HHS response for performing EI is within 48 hours*.

*Environmental Investigation Response Timeline
<5 ug/dL / HHS schedule permitting
5 – 10 ug/dL / 2 weeks
10 - <45 ug/dL / 1 week
≥45 ug/dL / 48 hours